The FTC is proposing ..."greater transparency and consumer control" ... These are the most important elements in any proposed self-regulation framework. It is NOT just about behavioral advertising. Greater transparency and consumer control should be applied to a wider construct than just behavioral advertising. Data is not being collected just to provide ads targeted to the consumer.

For example, data is also collected for interchange between social networking sites (which may later be used for behavioral advertising). Data is also collected to be sold (either raw or anonymized) - are you OK with someone else making money from selling your data without paying you even a penny?

On another front, Data Portability is a powerful concept. So, then, is Privacy Portability. Let's also focus on driving some privacy standards around OpenID, FOAF and XFN ... what are these? Watch this blog further for more about identity interoperability in a Web 2.0 world ... remember, the identity is attached to the data.

Additionally, data is correlated with offline data sources. Let's also propose a level of transparency as to how the correlated data is used.

Finally, let's even have employers declare that they actively search LinkedIn profiles, Facebook and MySpace accounts and consider this information in the employement assessment process .

Directly from the FTC site:

For more than a decade, the FTC has engaged in investigation, law enforcement, studies, and other privacy developments to protect consumers’ privacy online. Concepts used to develop the principles emerged from the agency’s longstanding privacy program and, more recently, from two conferences hosted by the FTC. In the fall of 2006, a three-day public hearing, “Protecting Consumers in the Next Tech-ade,” examined technology developments that could raise consumer protection policy issues, including privacy, over the next decade. This past November, building on the Tech-ade hearings, the FTC hosted a Town Hall entitled “Ehavioral Advertising: Tracking, Targeting, and Technology,” to focus in on privacy issues raised by behavioral advertising.

“The purpose of this proposal is to encourage more meaningful and enforceable self-regulation to address the privacy concerns raised with respect to behavioral advertising. In developing the principles, FTC staff was mindful of the need to maintain vigorous competition in online advertising as well as the importance of accommodating the wide variety of business models that exist in this area,” according to its proposal “Behavioral Advertising: Moving the Discussion Forward to Possible Self-Regulatory Principles.” The proposal states that behavioral advertising provides benefits to consumers in the form of free content and personalized advertising but notes that this practice is largely invisible and unknown to consumers.

[Note … highlighting and underscoring below added for emphasis]

To address the need for greater transparency and consumer control regarding privacy issues raised by behavioral advertising, the FTC staff proposes:

• Every Web site where data is collected for behavioral advertising should provide a clear, consumer-friendly, and prominent statement that data is being collected to provide ads targeted to the consumer and give consumers the ability to choose whether or not to have their information collected for such purpose.

To address the concern that data collected for behavioral advertising may find its way into the hands of criminals or other wrongdoers, and concerns about the length of time companies are retaining consumer data, the FTC staff proposes:

• Any company that collects or stores consumer data for behavioral advertising should provide reasonable security for that data and should retain data only as long as is necessary to fulfill a legitimate business or law enforcement need.

To address the concern that companies may not keep their privacy promises when they change their privacy policies, FTC staff proposes:

• Companies should obtain affirmative express consent from affected consumers before using data in a manner materially different from promises the company made when it collected the data.

To address the concern that sensitive data – medical information or children’s activities online, for example – may be used in behavioral advertising, FTC staff proposes:

• Companies should only collect sensitive data for behavioral advertising if they obtain affirmative express consent from the consumer to receive such advertising.

FTC staff also seeks comment on what constitutes “sensitive data” and whether the use of sensitive data should be prohibited, rather than subject to consumer choice.

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